V20667 - Pinal County, Arizona · PDF file ·...
Transcript of V20667 - Pinal County, Arizona · PDF file ·...
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
1 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
SUNDANCE POWER PLANT - CASA GRANDE
1. INTRODUCTION ............................................................................................................................................. 4
2. LISTING OF (FEDERALLY ENFORCEABLE) APPLICABLE REQUIREMENTS ........................................................... 4
3. PROSPECTIVE COMPLIANCE REQUIREMENTS ................................................................................................ 6
A. COMPLIANCE PLAN ................................................................................................................................................ 6 B. COMPLIANCE SCHEDULE ......................................................................................................................................... 6
1. Risk Management Program and Plan .......................................................................................................... 6
4. AUTHORITY TO CONSTRUCT .......................................................................................................................... 6
A. CT SYSTEM REQUIREMENTS .................................................................................................................................... 7 B. PSD EMISSION LIMITS ............................................................................................................................................ 8
1. Definitions .................................................................................................................................................... 8 2. Emission Limitations and Associated Requirements .................................................................................... 8
C. FUEL USE LIMITATIONS ......................................................................................................................................... 10 1. CT Fuels ...................................................................................................................................................... 10 2. Diesel Driven Fire Pump.............................................................................................................................. 10
D. TIMING AND PROGRESS OF CONSTRUCTION .............................................................................................................. 10
5. EMISSION LIMITATIONS AND CONTROLS .................................................................................................... 10
A. APPLICABLE LIMITATIONS ...................................................................................................................................... 10 B. ALLOWABLE EMISSIONS ........................................................................................................................................ 11 C. EMISSION LIMITS ................................................................................................................................................. 11
1. NSPS Subpart GG Limitations ..................................................................................................................... 11 2. NESHAP Limitations on Emergency Compression Ignition Engines ............................................................ 11
D. FUEL-BURNING EQUIPMENT - PARTICULATE EMISSIONS .............................................................................................. 12 1. SIP Limitation ............................................................................................................................................. 12 2. Current Code Limitation ............................................................................................................................. 12
E. PARTICULATE EMISSIONS - CONTROL OF FUGITIVE DUST ............................................................................................. 12 F. GENERALLY APPLICABLE OPACITY LIMITS .................................................................................................................. 13
1. SIP Limitation ............................................................................................................................................. 13 2. Visibility Limiting Standard ......................................................................................................................... 13 3. Code Limitation ROTATING EQUIPMENT ONLY .......................................................................................... 13
G. REASONABLE PRECAUTIONS ................................................................................................................................... 14 H. SURFACE STABILIZATION ....................................................................................................................................... 14 I. ADDITIONAL PLANT-WIDE REQUIREMENTS ............................................................................................................... 15
1. Sandblasting - Plant Wide .......................................................................................................................... 15 2. Architectural Coatings ................................................................................................................................ 16 3. Other Spray Painting .................................................................................................................................. 16 4. Disposal ...................................................................................................................................................... 16 5. Cutback and Emulsified Asphalt ................................................................................................................. 16 6. Solvent Cleaning ......................................................................................................................................... 17
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
2 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
K. GENERALLY APPLICABLE LIMITS .............................................................................................................................. 18 1. Asbestos NESHAP Compliance .................................................................................................................... 18 2. Stratospheric Ozone and Climate Protection ............................................................................................. 18
L. ACID RAIN REQUIREMENTS .................................................................................................................................... 18 M. EMERGENCY RISK MANAGEMENT AND EMERGENCY RESPONSE PLAN REQUIREMENTS .................................................. 19
1. Chemical Accident Prevention Requirements ............................................................................................. 19
6. COMPLIANCE DEMONSTRATION ................................................................................................................. 19
A. TESTING............................................................................................................................................................. 19 1. Performance Test Methodology ................................................................................................................. 20 2. Performance Test Methods ........................................................................................................................ 20 3. Performance Testing Schedule ................................................................................................................... 21 4. Test Protocol .............................................................................................................................................. 21 5. Performance Test Notices .......................................................................................................................... 21
B. MONITORING ..................................................................................................................................................... 22 1. Instrumental emissions monitoring - oxides of nitrogen ............................................................................ 22 2. Instrumental emissions monitoring - Carbon monoxide ............................................................................ 22 3. General parametric emission monitoring requirements ............................................................................ 23 4. Parametric emissions monitoring - Volatile organic compounds ............................................................... 24 5. Parametric Emissions monitoring - Particulate matter .............................................................................. 24 6. Parametric emissions monitoring - sulfur dioxide ...................................................................................... 24 7. Periodic monitoring - Emergency Fire Pump Fuel Sulfur Content. .............................................................. 25 8. Parametric emission monitoring - Minimum Load Operation .................................................................... 25 9. Parametric emission monitoring - General Maintenance .......................................................................... 25 10. Parametric emission monitoring - Operating Cycle ............................................................................... 25 11. Parametric emission monitoring - Startup Events ................................................................................. 25
C. NESHAP MONITORING AND COMPLIANCE FOR EMERGENCY COMPRESSION IGNITION ENGINES ......................................... 25 D. RECORDKEEPING ................................................................................................................................................. 27 E. COMPLIANCE REPORTING ...................................................................................................................................... 28 F. REGULAR COMPLIANCE/COMPLIANCE PROGRESS CERTIFICATION .................................................................................. 28
7. OTHER REPORTING OBLIGATIONS ............................................................................................................... 29
A. DEVIATION REPORTING REQUIREMENT .................................................................................................................... 29 B. ANNUAL EMISSIONS INVENTORY ............................................................................................................................. 29 C. GREENHOUSE GAS REPORTING ............................................................................................................................... 29
8. FEE PAYMENT .............................................................................................................................................. 29
9. GENERAL CONDITIONS ................................................................................................................................ 29
A. TERM ................................................................................................................................................................ 29 B. BASIC OBLIGATION .............................................................................................................................................. 30 C. DUTY TO SUPPLEMENT APPLICATION ....................................................................................................................... 30 D. RIGHT TO ENTER ................................................................................................................................................. 30 E. TRANSFER OF OWNERSHIP .................................................................................................................................... 31 F. POSTING OF PERMIT ............................................................................................................................................ 31
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
3 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
G. PERMIT REVOCATION FOR CAUSE ........................................................................................................................... 31 H. CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS ........................................................................................ 31 I. EXPIRATION AND RENEWAL OF PERMIT .................................................................................................................... 31 J. SEVERABILITY ...................................................................................................................................................... 32 K. PERMIT SHIELD ................................................................................................................................................... 32 L. PERMIT REVISIONS ............................................................................................................................................... 32 M. PERMIT RE-OPENING ....................................................................................................................................... 33 N. RECORD RETENTION ............................................................................................................................................. 34 O. SCOPE OF LICENSE CONFERRED .............................................................................................................................. 34 P. EXCESS EMISSION REPORTS; EMERGENCY PROVISION ................................................................................................. 34
10. ADDITIONAL PROVISIONS APPLICABLE TO TITLE V SOURCES ................................................................... 36
A. ENFORCEMENT BY THE ADMINISTRATOR AND CITIZENS ............................................................................................... 36 B. FEDERAL ENFORCEABILITY EXCLUSIONS .................................................................................................................... 36
11. EQUIPMENT ............................................................................................................................................ 36
12. INSIGNIFICANT ACTIVITIES ...................................................................................................................... 37
APPENDIX A ......................................................................................................................................................... 39
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
4 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
1. Introduction
This permit renewal pertains to an existing electrical power plant, owned and operated by
Arizona Public Service Company, an Arizona corporation. The SIC Code is 4911. The facility,
commonly known as Sundance Power Plant, is located on 2060 West Sundance Road, Casa
Grande. The source is situated in an area classified as non-attainment for PM10 and attainment
for all other pollutants.
The plant currently includes ten natural gas fired combustion turbine ("CT") with a nominal
rating of 45 mw each. Each CT system has a separate stack. The control configuration includes
water injection followed by selective catalytic reduction (SCR), as well as an oxidation catalyst.
The plant is a "major emitting source" of CO, PM10 and NOx. That status requires that this
permit implement the "Prevention of Significant Deterioration" (PSD) requirements defined in
the Clean Air Act (1990) ("CAA"). See the 2001 TSDs for a discussion of the Best Available
Control Technology (BACT) determination, as well as other PSD-related issues. The source is
also subject to the operating permit requirements under Title V of the CAA. This permit will
provide authority-to-construct under the PSD program, and authority-to-operate under the Title V
program.
For clarification, as required by 40 CFR §70.6(b), all provisions of this permit, other than those
expressly identified in permit section 10.B, are federally enforceable.
The Technical Support Document for this permit includes a permitting history section, as well as
a summary of any applicable requirements updates or changes made during this renewal.
2. Listing of (Federally Enforceable) Applicable Requirements
[Mandated by 40 CFR §70.5a(4)]
A. Those portions of Pinal County Air Quality Control District ("PCAQCD") Regulations
("Code"), as revised by the Pinal County Board of Supervisors on October 12, 1995, and
approved by the Administrator as elements of the Arizona State Implementation Plan
("SIP") at 61 FR 15717 (4/9/96). The following all specifically pertain to the issuance of
this initial permit:
§3-1-040 Applicability and Classes of Permits
§3-1-050 Permit Application Requirements
§3-1-081 Permit Conditions
§3-1-082 Emission Standards and Limitations
§3-1-083 Compliance Provisions
§3-1-103 Annual Emissions Inventory Questionnaire
§3-1-132 Permit imposed right of entry
§3-1-150 Monitoring
§3-1-160 Test Methods and Procedures
§3-1-170 Performance Tests
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
5 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
§3-1-173 Quality Assurance
§3-1-177 Stack Height Limitation
§§3-3-200 through 3-3-210, and 3-3-250 through 3-3-280 - Permit Requirements for New
Major Sources ... [Located in Attainment Areas]
B. Those specific provisions of the Pinal-Gila Counties Air Quality Control District
("PGCAQCD") Regulations, as adopted by the Pinal County Board of Supervisors on
March 31, 1975, and approved by the Administrator as elements of the Arizona State
Implementation Plan ("SIP") at 43 FR 53034 (11/15/78), and specifically the following
rules:
7-3-1.2 Emission Standards - Particulate Emissions - Fugitive Dust
7-3-5.1 NOx Emissions - Fuel Burning Equipment
C. Those specific provisions of the PGCAQCD Regulations, as last amended by the Pinal
County Board of Supervisors on June 16, 1980, and approved by the Administrator as
elements of the Arizona SIP at 47 FR 15581 (4/12/82), specifically, the following rules:
7-3-1.1 Visible Emissions; General
7-3-1.7.F Fuel Burning Equipment
D. The New Source Performance Standards ("NSPS") 40 CFR Part 60, Subpart GG -
Stationary Gas Turbines, §§60.330 - 60.335, Code §6-1-030.39
E. CAA §112(r) (11/15/90); 40 CFR Part 68 (7/31/98); Chemical Accident Prevention
Provisions
F. Acid Rain Provisions; CAA Title IV, and:
40 CFR Part 72 Permit Regulation - Code §3-6-565
40 CFR Part 73 Sulfur Dioxide Allowance System - Code §3-6-565
40 CFR Part 75 Continuous Emission Monitoring (Acid Rain Program) - Code §3-6-565
G. CAA §§608 & 611 (11/15/90); 40 CFR Part 82, Subpart F - Recycling and Emissions
Reduction (9/7/95); regulations pertaining to use and handling of ozone-depleting
substances.
H. Those specific provisions of the PCAQCD Regulations, as last amended by the Pinal
County Board of Supervisors on April 27, 2004, and approved by the Administrator as
elements of the Arizona SIP at 75 FR 17307 (4/6/10), specifically, the following rule:
§4-2-040 Standards (Fugitive Dust Reasonable Precautions)
I. Those specific provisions of the PCAQCD Regulations, as last amended by the Pinal
County Board of Supervisors on May 18, 2005, and approved by the Administrator as
elements of the Arizona SIP at 71 FR 15043 (3/27/06), specifically, the following rule:
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
6 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
§2-8-300 (Opacity) Performance Standards
J. National Emissions Standards for Hazardous Air Pollutants, 40 CFR Part 63, Subpart
ZZZZ, Internal Combustion Engines[40 CFR §63.6080 - 6175].
3. Prospective Compliance Requirements
A. Compliance Plan
[Mandated by 40 CFR §70.(5)(c)(8)] (Code §3-1-083A.7)
Insofar as the Permittee is currently in compliance, the compliance plan consists of
continued adherence to the requirements of this permit and those requirements set forth in
applicable regulations and statutes.
B. Compliance Schedule
[Mandated by 40 CFR §§ 70.5(c)(8), 70.6(c)(3)] (Code §3-1-083.A.7)
Insofar as the Permittee is currently in compliance, no compliance schedule to attain
compliance is required, with the following exception:
1. Risk Management Program and Plan
If the source has more than a threshold quantity of a regulated substance in a
process as determined under 40 CFR 68.115, Permittee shall conform in a timely
manner to requirements applicable to this source under CAA §112(r) and 40 CFR
part 68, including at a minimum:
a. Submittal of a complete risk management plan ("RMP") to the District or
other state or local agency designated by the state for this purpose, by
such deadline as may be established under 40 CFR Part 68. The RMP
submittal shall include a certification that the plan is complete and
accurate;
b. Submittal of any additional information required for completeness;
c. Annual certification of implementation of the risk management program
as described by the RMP.
4. Authority to Construct
[Federally enforceable - Code §§3-1-010, 3-1-040 (as amended 10/12/95) approved as a SIP
Element at 65 FR 79741 (12/20/00)]
Emissions from this facility, specifically the equipment described in "Equipment Schedule"
section below, and the operating configuration as defined below and more fully described in the
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
7 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
application for permit, fall subject to the enforceable limitations identified throughout this permit.
Therefore, based on the regulations in effect upon the date of issuance of this permit and a finding
that allowable emissions from the equipment described in the Equipment Schedule will neither
cause nor contribute to a violation of any ambient air quality standard even without any additional
limitations, this permit constitutes authority to construct and operate such equipment. For
purposes of future revision to the permit for this facility, each of the limitations of this permit
section shall be considered "PSD" limitations.
A. CT System Requirements
(Code §3-3-250.A.1)
1. Each CT unit shall:
a. incorporate a system for the reduction of NOx, which shall consist of a
system for the selective catalytic reduction of NOx, including ammonia
injection and a catalyst system that will meet the operational limitations
of this permit;
b. incorporate a system for the reduction of CO, which shall consist of a
system for the catalytic oxidation of CO that will meet the operational
limitations of this permit;
c. exhaust to the atmosphere through a stack not greater than 10.5' in outlet
diameter, nor less than 85' in height;
d. each stack shall be equipped with such platforms and sampling ports as
may be required to fulfill the testing and monitoring requirements set
forth below;
e. include separate fuel-flow meters for each respective CT.
f. include NOx and CO monitoring systems as defined in the compliance
provisions of this permit.
g. include systems for monitoring and recording the inlet temperature for
each of the turbine units.
2. For each turbine unit, Permittee shall limit the aggregate number of annual
operating hours, including startup and shutdown operations, to no more than
7,500 hours in any rolling 12-month period.
3. Permittee shall limit the number of startup events for each CT unit to no more
than 1,000 such events in any rolling 12-month period.
4. Except for emergencies, the diesel-driven fire pump shall not be operated more
than 100 hours per calendar year.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
8 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
B. PSD Emission Limits
1. Definitions
a. “Start-up” is defined as the 15-minute period following the indication of
a Unit On signal.
b. "Warm-up" is defined as the 24-minute period following "start-up."
c. “Shutdown” is defined as the period beginning with the indication of the
Shutdown signal and ending with the Unit Off signal.
d. “Malfunction” is defined as any sudden and unavoidable failure of air
pollution control equipment, process equipment or a process to operate in
a normal and usual manner, but does not include failures that are caused
by poor maintenance, careless operation or any other upset condition or
equipment breakdown which could have been prevented by the exercise
of reasonable care.
2. Emission Limitations and Associated Requirements
(Code §3-3-250.)
a. CT Emission Rate Limitations
Other than during periods of start-up, warm-up, shut-down, and
malfunction, Permittee shall not cause to be discharged into the
atmosphere from any of the gas turbine systems during CT operations
any gases which:
1. contain nitrogen oxides emissions in excess of 5.0 ppmvd
corrected to 15 percent oxygen, based on a rolling, accumulating
3-operating hour average.
2. contain carbon monoxide emissions in excess of any of the
following temperature-specific concentration limitations, based
on correction to 15% oxygen, and a rolling, accumulating 3-
operating hour average:
i. 15.0 ppmvd below 59̊ F.; and
ii. 7.5 ppmvd at or above 59̊ F.
3. contain PM10 emissions in excess of 7.0 lbs/hr.;
4. contain VOC emissions in excess of 4.5 lbs/hr.;
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
9 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
5. exhibit opacity in excess of 40%, as measured by Method 9.
b. CT Start-up and Warm-up Limitations and Requirements
1. During start-ups of the CT units, the Permittee shall be exempt
from any limitations on emission of NOx, but Permittee shall
exercise "good combustion practice," consisting of adherence to
standard operating procedure.
2. During warm-ups of the CT units, Permittee shall limit the
average NOx emissions to 25 ppmvd @ 15% O2 as determined by
an average of 24 minutes of warm-up emissions data.
Substituted data should not be used to determine compliance
with this limit.
3. For emission inventory purposes, Permittee shall use the
following emissions during a combined start-up and warm-up
event:
A. NOx – 18.61 lbs
B. CO – 7.36 lbs
C. VOC – 1.73 lbs
c. CT Shutdown Limitations and Requirements
1. During shutdown of the CT units, the Permittee shall be exempt
from any limitations on emission of NOx, but Permittee shall
exercise "good combustion practice," consisting of adherence to
standard operating procedure.
2. For emission inventory purposes, Permittee shall use the
following emissions during a shutdown event:
A. NOx – 2.57 lbs
B. CO – 0.07 lbs
C. VOC – 0.08 lbs
3. If a CT unit shuts down within the 24-minute period immediately
following termination of the start-up period, and the conditions
of permit condition 4.B.1.c. have been met, the unit shall comply
with the requirements of this permit condition 4.B.2.c.
d. Minimum Operating Load
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
10 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
Other than during startup, warmup or shutdown or as a result of upset or
malfunction, Permittee shall not operate each of the CT units below a
minimum of 32% of baseload capacity (approximately 15 mW), based on
a 12-month rolling average.
e. Good Operating Practice
At all times, Permittee shall operate the CT units in accordance with the
manufacturer's specifications in order to minimize emissions of
particulate matter, carbon monoxide, and volatile organic compounds.
Permittee may transcribe those manufacturer's specifications into
standard operating procedures to be utilized by on-site staff.
C. Fuel Use Limitations
(Code §3-1-081.)
1. CT Fuels
(Code §3-3-250.A.1)
See permit condition §5.C.1.b
2. Diesel Driven Fire Pump
(Code §5-23-1020)
In the diesel driven fire pump, Permittee shall not burn diesel fuel having a sulfur
content exceeding 500 ppmw.
D. Timing and Progress of Construction
(Code §3-3-210.4)
This permit shall be subject to termination if the proposed construction on the first phase
(up to ten turbines) has not begun within 18 months of permit issuance, or if during the
construction work for the first phase is suspended for more than 18 months. The second
phase of construction for turbines authorized by this permit may commence at any time
during the term of this permit. However, for any turbine units that are not under
construction within 18 months of the issuance of this permit, then prior to commencing
construction on that second phase, the Permittee will need to first obtain a prior
significant revision to this permit in order to revisit the BACT determination for those
additional turbines.
5. Emission Limitations and Controls
[Mandated by 40 CFR §70.6(a)(1)]
A. Applicable Limitations
(Code §3-1-082)
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
11 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
Where different standards or limitations apply under this permit, the most stringent
combination shall prevail and be enforceable.
B. Allowable Emissions
(Code § 3-1-081.A.2.)
Permittee is authorized to discharge or cause to discharge into the atmosphere those
emissions of air contaminants as set forth in Sections 3, 4 and 5 of this permit. Unless
exempted as an insignificant activity under Code §1-3-140.79a, as a categorical
exemption under Code §3-1-040.C., or authorized by a separate permit or by a revision or
operational change allowed under this permit or under Chapter 3, Article 2 of the Code,
Permittee shall not commence construction of, operate or make any modification to this
source in a manner which will cause emissions of any regulated air pollutant in excess of
the 5.5lbs/day de minimis amount defined in Code §1-3-140.37.
C. Emission Limits
1. NSPS Subpart GG Limitations
[40 CFR 60.332 & 60.333] Code §6-1-030.
a. Permittee shall not cause to be discharged into the atmosphere from the
gas turbines any gases which contain nitrogen oxides in excess of:
STD = 0.0075(14.4)/Y
where STD = NOx emissions (% by volume at 15% oxygen and
on a dry basis)1
Y = rated heat load (kilojoules per watt) (not greater than 14.4)
b. In the CT units, Permittee is allowed to burn exclusively pipeline natural
gas, provided Permittee shall not burn natural gas having a hydrogen
sulfide content in excess of 1 grain 100 scf, or a total sulfur content in
excess of 20 grains/100 scf. For compliance reporting and emission
inventory purposes, permittee shall quantify SO2 emissions using an SO2
emission rate of 0.0006 lbs/mmBtu.
2. NESHAP Limitations on Emergency Compression Ignition Engines
<500 hp constructed before June 12, 2006 and located at minor sources of HAP
[40 CFR §§63.6595, 63.6603, 63.6605]
1 The turbines are rated at 446 mmBtu/hr (HHV) each; that mathematically reduces to an allowable NOx emission rate of
0.0075 percent by volume, or 75 ppmvd.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
12 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
Permittee shall comply with the limitations of Table 2d of 40 CFR Part 63,
Subpart ZZZZ no later than May 3, 2013.
Except during periods of startup, Permittee shall:
a. Change oil and filter or pass the oil analysis set forth in permit condition
§6.C.4 every 500 hours of operation or annually, whichever comes first;
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever
comes first;
c. Inspect all hoses and belts every 500 hours of operation or annually,
whichever comes first, and replace as necessary.
D. Fuel-Burning Equipment - Particulate Emissions
1. SIP Limitation
[Currently federally enforceable pursuant to PGAQCD Reg. 7-3-1.7 (3/31/75)
approved as a SIP element at 43 FR 50531 (11/15/78)]
For equipment with a heat input capacity of less than 4,000 million Btu per hour,
particulate emissions shall not exceed2:
E = 1.02X-.231, where E = maximum emissions in lbs./hr. for each million BTU
per hour heat input, and X = maximum heat input capacity in million BTU per
hour.
2. Current Code Limitation
(§5-23-1010)
For equipment with a heat input capacity of less than 4,200 million Btu per hour,
particulate emissions shall not exceed3:
E = 1.02Q0.769, where E = maximum emissions in lbs./hr. for each million BTU
per hour heat input, and Q = maximum heat input capacity in million BTU per
hour.
E. Particulate Emissions - Control of Fugitive Dust
2 The turbines are rated at 446 mmBtu/hr (HHV) each, and that mathematically reduces to an allowable
PM emission rate of 111.16 lb/hr.
3 The turbines are rated at 446 mmBtu/hr (HHV) each, and that mathematically reduces to an allowable
PM emission rate of 111.16lb/hr.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
13 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
[Currently federally enforceable pursuant to PGAQCD Reg. 7-3-1.2 (3/31/75) approved
as a SIP element at 43 FR 50531 (11/15/78)] (Code §§2-8-300. and 4-2-040.)
1. Permittee shall not cause, suffer, allow or permit a building or its appurtenances
or open area to be used, constructed, repaired, altered or demolished without
taking reasonable precautions to prevent particulate matter from becoming
airborne. Particulate emissions shall be kept to a minimum by such measures as
wetting down, covering, landscaping, paving, treating or by other reasonable
means.
2. Permittee shall not cause, suffer, allow or permit the repair, construction or
reconstruction of a roadway or alley without taking reasonable precautions to
prevent particulate matter from becoming airborne dust and other particulates
shall be kept to a minimum by employing temporary paving, dust palliatives,
wetting down, detouring or by other reasonable means. Earth or other material
shall be removed from paved streets onto which earth or other material has been
transported by trucking or earth moving equipment, erosion by water or by other
means.
F. Generally Applicable Opacity Limits
1. SIP Limitation
[Currently federally enforceable pursuant to PGAQCD Reg. 7-3-1.1 (6/16/80)
approved as a SIP element at 47 FR 15579 (4/12/82)]
The opacity of any plume or effluent shall not be greater than 40 percent as
determined by Reference Method 9 in the Arizona Testing Manual (ADEQ,
1992). Nothing in this limitation shall be interpreted to prevent the discharge or
emission of uncontaminated aqueous steam, or uncombined water vapor, to the
open air.
2. Visibility Limiting Standard
[Federally enforceable pursuant to Code §2-8-300 (5/18/05) approved as a SIP
element at 71 FR 15043 (3/27/06)]
The opacity of any plume or effluent from any point source not subject to a New
Source Performance Standard adopted under Chapter 6 of the Code, and not
subject to an opacity standard in Chapter 5 of the Code, shall not be greater than
20% as determined in Method 9 in 40 CFR 60, Appendix A.
3. Code Limitation ROTATING EQUIPMENT ONLY
(Code §5-23-1010)
Permittee shall limit the opacity of emissions from any stationary rotating
machinery, excluding the emergency fire pump, such that opacity does not
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
14 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
exceed 40% for longer than 10 consecutive seconds. Visible emissions when
starting cold equipment shall be exempt from the requirement of this
subparagraph for the first 10 minutes of operation.
G. Reasonable Precautions
[Currently federally enforceable pursuant to PCAQCD Reg. 4-2-040 (6/29/93)
approved as a SIP element at 72 FR 41896]
1. Permittee shall not cause, suffer, allow, or permit a building or its appurtenances,
subdivision site, driveway, parking area, vacant lot or sales lot, or an urban or
suburban open area to be constructed, used, altered, repaired, demolished,
cleared, or leveled, or the earth to be moved or excavated, or fill dirt to be
deposited, without taking reasonable precautions to effectively prevent fugitive
dust from becoming airborne.
2. Permittee shall not cause, suffer, allow, or permit a vacant lot, or an urban or
suburban open area, to be driven over or used by motor vehicles, such as but not
limited to all-terrain vehicles, trucks, cars, cycles, bikes, or buggies, without
taking reasonable precautions to effectively prevent fugitive dust from becoming
airborne.
3. Permittee shall not disturb or remove soil or natural cover from any area without
taking reasonable precautions to effectively prevent fugitive dust from becoming
airborne.
4. Permittee shall not cause, suffer, allow or permit transportation of materials
likely to give rise to fugitive dust without taking reasonable precautions to
prevent fugitive dust from becoming airborne. Earth and other material that is
tracked out or transported by trucking and earth moving equipment on paved
streets shall be removed by the party or person responsible for such deposits.
5. Permittee shall not cause, suffer, allow or permit the use, repair, construction or
reconstruction of any road or alley without taking every reasonable precaution to
effectively prevent fugitive dust from becoming airborne.
H. Surface Stabilization
[Code §4-1-030, adopted 10/28/15, effective 1/1/16]
1. Permittee shall not cause or allow visible fugitive dust emissions from open areas
/ vacant lots (areas not currently utilized for an activity) to exceed 20% opacity
based on EPA Method 9 or the continuous plume or intermittent plume methods
listed in PCAQCD Code §4-9-340.
2. Permittee shall erect barriers or no trespassing signs upon evidence of trespass on
open areas / vacant lots.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
15 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
3. Permittee shall stabilize any open area / vacant lot greater than 1.0 acre that has
0.5 acre or more of disturbed surface and sign up for the Pinal County Dust
Control forecast within 30 days of discovery. The open area / vacant lot shall be
stabilized the day leading up to and the day that is forecast to be high risk for
dust emissions.
4. Permittee shall not remove vegetation from open areas / vacant lots without
applying dust suppressants before and during the weed abatement. Trackout onto
paved surfaces must be prevented or eliminated and dust suppressants must be
applied following weed abatement to stabilize the entire surface.
5. Stabilization of open areas / vacant lots is determined by the drop ball, threshold
friction velocity, flat vegetation or standing vegetation methods listed in
PCAQCD Code 4-9-320.
6. Permittee shall not cause or allow visible fugitive dust emissions from unpaved
lots (areas being utilized for an activity) greater than 5000 square feet to exceed
20% opacity based on EPA Method 9 or the continuous plume or intermittent
plume methods listed in PCAQCD Code §4-9-340.
7. Permittee shall not allow silt loading equal to or greater than 0.33 oz/ft2 or allow
the silt content to exceed 8% on unpaved lots greater than 5000 square feet.
8. Permittee shall stabilize unpaved lots greater than 5000 square feet by paving,
applying a dust suppressant or graveling.
9. Permittee shall clean up trackout on a paved public roadway that exceeds 50 feet
within 24 hours of discovery and limit opacity to 20% or less while using a rotary
brush or broom.
10. Permittee shall make a record of the control measures applied.
I. Additional Plant-Wide Requirements
1. Sandblasting - Plant Wide
(Code §5-4-160.)
Permittee shall use at least one of the following control measures during
sandblasting operations:
a. Vacuum collection system.
b. Confined blasting.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
16 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
c. Wet abrasive blasting.
d. Hydroblasting.
e. A control measure that is determined by the Control Officer to be equally
effective to control particulate matter emissions.
2. Architectural Coatings
(Code §5-12-370)
Permittee shall not employ, apply, evaporate or dry any architectural coating, as
defined in §5-12-370.C, for industrial or commercial purposes, material
containing photochemically reactive solvent as defined in §5-9-280 or shall thin
or dilute any architectural coating with a photochemically reactive solvent.
3. Other Spray Painting
(Code §5-13-390)
Permittee shall conduct spray painting operations except architectural coatings in
an enclosed area designed to contain not less than 96% by weight of the
overspray. An enclosed area means a 3-sided structure with walls a minimum of
8 feet high.
4. Disposal
(Codes §$5-12-370 and 5-13-390)
Permittee shall not, during any one day, dispose of a total of more than one and
one-half gallons of any photochemically reactive solvent or of any material
containing more than one and one-half gallons of any such photochemically
reactive solvent by any means which will permit the evaporation of such solvent
into the atmosphere.
5. Cutback and Emulsified Asphalt
(Code §5-16-670)
Except as exempted in §5-16-680, Permittee:
a. Shall not use or apply the following materials for paving, construction or
maintenance:
i. Rapid cure cutback asphalt;
ii. Any cutback asphalt material, road oils or tar which contains
more than 1.5% by volume VOCs which evaporate at 500̊F or
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
17 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
less using ASTM Test Method D-402-76 or more than 27% by
volume total solvent in the asphalt binder.
iii. Any emulsified asphalt or emulsified tar containing more than
3% by volume VOCs which evaporate at 500̊F or less using
ASTM Test Method D-244-89.
b. Shall not store within Pinal County any emulsified or cutback asphalt
product which contains more than 1.5% by volume solvent-VOC unless
such material lot included a designation of solvent-VOCcontent on data
sheet(s) expressed in percent solvent-VOC by volume.
6. Solvent Cleaning
(§5-15-620)
a. Solvent cleaners/degreasers shall:
i. Provide a leak-free container for solvents and articles being
cleaned;
ii. Except for a remote reservoir cleaner using unheated solvent, be
equipped with a cover which prevents the solvent from
evaporating when not processing work;
iii. Be equipped with a drain configured to return solvent drained
from cleaned parts to the container;
iv. Be clearly labeled to identify the solvent and explain the proper
operation of the cleaner;
v. A degreaser/cleaner with a remote reservoir shall be equipped
with a sink-like work area sloped sufficiently toward a drain so
as to prevent pooling of the solvent, a drain from the sink to the
reservoir, with a maximum drain area of 15.5 in2, and unless a
low-volatility solvent with a boiling point above 248̊ f is utilized
and the solvent is never heated above 120̊ f., a stopper shall be
used to seal the drain opening or a cover placed over the sink
when the device is not in use.
vi. For a degreaser/cleaner without a remote reservoir, if the
degreaser utilizes a low-volatility solvent with a boiling point
above 248̊ f., and the solvent is not agitated in use, Permittee
shall maintain a minimum 6" freeboard and keep the cover
closed when the apparatus is not in use; or if using solvents
which are not low volatility or which are agitated or are heated
above 120̊ F shall have internal drainage and a freeboard ratio of
0.75 or greater; or a water cover may be used to meet the
freeboard requirement if the solvent is insoluble in and denser
than water; and a cover shall be used that is of a sliding or rolling
type which is designed to easily open and close without
disturbing the vapor zone. The degreaser/cleaner shall be
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
18 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
equipped with a clear and conspicuous mark for the maximum
allowable solvent level; and as an alternative to the foregoing
freeboard requirement, be equipped with a hood or enclosure
with a ventilation rate of no less than 65 cfm per ft.2 of
evaporative surface, unless a more stringent requirement applies
pursuant to OSHA requirements, and the overall control
efficiency of emissions from the cleaner, considering both
capture and destruction, shall not be less than 85%.
b. Permittee shall operate the cold solvent cleaners/degreasers in
accordance with the operating requirements listed in Code §5-15-620.H.
Each cold solvent/degreaser shall have a permanent, conspicuous label
which summarizes the relevant operating requirements.
J. General Maintenance Obligation
[40 CFR 60.11(d), A.R.S. §49-514(J), Code §§3-1-081.E., 8-1-030.A.3]
At all times, including periods of start-up, shutdown, and malfunction, owners and
operators shall, to the extent practicable, maintain and operate the permitted facility
including associated air pollution control and monitoring equipment in a manner
consistent with good air pollution control practice for minimizing emissions.
K. Generally Applicable Limits
1. Asbestos NESHAP Compliance
[Currently federally enforceable; 40 CFR Part 61, Subpart M] (Code §§7-1-
030, 7-1-060)
Permittee shall comply with Code §§7-1-030.A. and 7-1-060 and 40 CFR Part
61, Subpart M, when conducting any renovation or demolition activities at the
facility.
2. Stratospheric Ozone and Climate Protection
[Currently federally enforceable; 40 CFR Part 82 Subpart F]
The permittee shall comply with the standards for recycling and emissions
reduction pursuant to 40 CFR Part 82, Subpart F, Recycling and Emissions
Reduction.
L. Acid Rain Requirements
(Code §§3-6-565, 3-1-081.A.6)
1. When provisions or requirements of the regulations incorporated pursuant to
Code §3-6-565 (i.e. the Acid Rain Program) conflict with any of the other
applicable requirements set forth in this permit, the regulations incorporated
under §3-6-565 shall apply and take precedence.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
19 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
2. No permit revision shall be required for increases in emissions that are authorized
by allowances acquired pursuant to the Acid Rain Program, provided that such
increases do not require a permit revision under any other applicable
requirement. Code §3-1-081.A.6.a.
3. No limit shall be placed on the number of allowances held by the source. The
source may not, however, use allowances as a defense to noncompliance with
any other applicable requirement. Code §3-1-081.A.6.b.
4. Any such allowance shall be accounted for according to the procedures
established in regulations promulgated under Part IV of the CAA, commonly
known as CAA Title IV. Code §3-1-081.A.6.c.
5. All of the following are prohibited: (Code §3-1-081.A.6.d.)
a. Annual emissions of sulfur dioxide in excess of the number of
allowances to emit sulfur dioxide held by the owners or operators of the
unit or the designated representative of the owners or operators.
b. Exceedances of applicable emission rates specified in this permit.
c. The use of any allowance prior to the year for which it was allocated.
d. Contravention of any other provision of this permit.
M. Emergency Risk Management and Emergency Response Plan Requirements
1. Chemical Accident Prevention Requirements
[Currently federally enforceable; 40 CFR Part 68]
If the facility is subject to 40 CFR Part 68 by having more than a threshold
quantity of ammonia, the permittee shall comply with the planning requirements
set forth in 40 CFR Part 68 with regard to the ammonia-handling and ammonia-
storage at the facility, as well as any other process or facility affected under 40
CFR Part 68, including:
a. Submittal of a compliance schedule as required under 40 CFR Part 68,
by the date required under 40 CFR §68.10(a); or
b. As part of the compliance certification submitted under 40 CFR
§70.6(c)(5), a certification statement that the source is in compliance
with all requirements of 40 CFR Part 68, including the registration and
submission of a release management plan.
6. Compliance Demonstration
A. Testing
[Mandated by 40 CFR §70.6(a)(3)]
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
20 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
1. Performance Test Methodology
(Code §3-1-160.D) [Currently federally enforceable pursuant to PCAQCD
Code 3-1-160 (11/03/93) approved as a SIP element at 65 FR 79742]
Except for ambient air monitoring and emissions testing required under a NSPS
or NESHAP, alternate sampling techniques or other means to determine opacity,
rate, composition, and/or concentration of emissions in any test plan submitted to
the Control Officer may be approved by the Control Officer for the duration of
that plan provided that the following four criteria are met:
a. The alternative or equivalent test method measures the same chemical
and physical characteristics as the test method it is intended to replace.
b. The alternative or equivalent test method has substantially the same or
better reliability, accuracy, and precision as the test method it is intended
to replace.
c. Applicable quality assurance procedures are followed in accordance with
the Arizona Testing Manual, 40 CFR Part 60 or other methods approved
by the Control Officer.
d. This approval does not include nondelegable functions of the EPA
Administrator, including but not limited to approval of alternative or
equivalent test methods. As used in 40 C.F.R. 60: "Administrator" means
the Control Officer of the Pinal County Air Quality Control District,
except that the Control Officer shall not be authorized to approve
alternate or equivalent test methods, alternative work standards or work
practices, equivalency determinations or innovative technology waivers
as covered in Section 111(h) "Design, equipment, work practice, or
operational standard, alternative emission limitation," and Section 111(k)
"Innovative technological systems of continuous emission reduction" of
the FCAA."
2. Performance Test Methods
[40 CFR 60.8, Code §§3-1-160 & 3-1-170)
At such times as defined below, the owner or operator shall conduct
performance tests and shall furnish the Control Officer a written report of the
results of the tests as provided below. Permittee shall conduct performance tests,
using standard test methods specified below, or equivalent methods as approved
by the District pursuant to approval of the test plan required below. The tests
shall be conducted using standard test methods approved by the EPA (40 CFR
Part 60). These tests shall be performed at the maximum practical production
rate. A test plan protocol for each test shall be submitted to the District at least
thirty (30) days before the testing. The continuous monitoring systems required
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
21 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
by this permit shall be in place and operating prior to conducting the performance
tests.
a. nitrogen oxides emissions Ref. Part 60, App. A, Ref. Method 7e or
subsidiary method
b. carbon monoxide emissions Ref. Part 60, App. A, Ref. Method 10
c. particulate matter emissions (filterable PM10) Ref. Part 60, App. A, Ref.
Method 5 or 201A and (condensable PM10) Method 202
d. volatile organic compound emissions Ref. Part 60, App. A, Ref. Method
25a
e. opacity Ref. Part 60, App. A, Ref. Method 9, 40 CFR §60.11
3. Performance Testing Schedule
(Code §3-1-050)4
In addition to the monitoring requirements pertaining to NOx and CO listed in
Subsection B. below, at least once during the year 2012 and during every
subsequent 5-year permit term, Permittee shall conduct recurring performance
tests for VOCs and PM10 using the test methods listed above. Two CTs may be
selected for testing and used to represent all of the identical CTs at the facility to
meet this requirement and used for emissions calculations and emissions
inventory. Selection of the two CTs used shall be rotated for each subsequent
testing.
4. Test Protocol
A test plan protocol for each test shall be submitted to the District for approval at
least thirty (30) days before the testing. The protocol shall specifically identify
which CTs are to be tested for compliance demonstration.
5. Performance Test Notices
Notice of any performance test required by this permit shall be submitted to the
District at least five days prior to running the test.
6. Test Reports
A copy of each test report shall be submitted to the District for approval within
forty-five days after the test. In addition to any other information required under
this permit, the Test Report for all mandatory tests shall specifically define:
4
The initial Title V permit for this facility did not require recurring testing for VOC and PM10 and therefore the testing data used for purposes of
emissions calculations and emissions inventory dates back to 2002. In order to obtain more current data, PCAQCD has added a recurring
schedule for these pollutants as part of this renewal, which will also make this permit’s testing schedule consistent with other electric utility
permits.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
22 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
a. NOx emissions rates, defined as both as a function of heat input, and
expressed in the same units as the NOx emission limitations imposed
under this permit.
b. CO emissions rates, defined as both as a function of heat input, and
expressed in the same units as the CO emission limitations imposed
under this permit.
c. VOC emissions rates, defined both as a function of heat input, and
expressed in the same units as the VOC emission limitations imposed
under this permit.
d. PM10 emission rates, defined both as a function of heat input, and
expressed in the same units as the PM10 emission limitations imposed
under this permit.
B. Monitoring
[Mandated by 40 CFR §70.6(a)(3)]
1. Instrumental emissions monitoring - oxides of nitrogen
[40 CFR 60.334(b), Code §3-3-260.G.]
Permittee shall install, calibrate, maintain, and operate a continuous monitoring
system, and record the output of the system, for measuring:
a. nitrogen oxides emissions from the CT discharged to the atmosphere.
b. either the oxygen or carbon dioxide content of flue gas from each of the
CT units, with the measurement taken where the NOx emissions are
monitored.
c. Monitoring equipment required under this permit subsection shall be
installed, operated, and quality assured in accordance with the
requirements of 40 CFR Part 75.
Permittee shall conduct NOx CEMs evaluations in accord with the RAA
and RATA requirements for NOx CEMs, under 40 CFR Part 75,
Appendix A. Evaluations shall be conducted at least annually unless the
unit qualifies for an extension under 40 CFR Part 75, Appendix B. The
deadline for the next RATA shall be no more than 8 calendar quarters
after the quarter in which a RATA was last performed. A 720 operating
hour grace period is available if the RATA cannot be completed by the
deadline.
2. Instrumental emissions monitoring - Carbon monoxide
[Code §3-3-260.G.]
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
23 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
a. Monitoring equipment required under this subsection shall be installed
and operated pursuant to a plan submitted to the District by the permittee
at least 60 days prior to the initial performance tests required under the
initial permit.
b. On each CT unit, Permittee shall install, calibrate, maintain, and operate
a continuous monitoring system, and record the output of the system, for
measuring carbon monoxide emissions to the atmosphere. Permittee
shall use the quality assurance provisions of 40 CFR Part 75 for the CO
monitoring systems with the exception that a quarterly Cylinder Gas
Audit (CGA) in accordance with 40 CFR Part 60 shall be conducted
every calendar quarter regardless of the instrument span. A CGA will
not be required on quarters in which a RATA is performed.
Permittee shall conduct CO CEMs evaluations in accord with 40 CFR
Part 60 Appendix B, Performance Specification 4. RATA evaluations
shall be conducted at least annually unless the unit qualifies for an
extension under 40 CFR Part 75, Appendix B. The deadline for the next
RATA shall be no more than 8 calendar quarters after the quarter in
which a RATA was last performed. A 720 operating hour grace period is
available if the RATA cannot be completed by the deadline.
c. On each CT unit, Permittee shall install, calibrate, maintain, and operate
a continuous inlet air temperature monitoring system, and shall record
the output of the system. The plan shall require inlet temperature
monitoring and data recording on consistent with the monitoring
requirements of 40 CFR 60.
3. General parametric emission monitoring requirements
[Code §3-3-260.G]
To provide a basis for the other aspects of parametric monitoring set forth below,
Permittee shall maintain operating logs detailing:
a. hours of operation for each CT unit, defining periods of normal operation
of CT operation, start-up periods, warm-up periods, and shut-down
periods.
b. fuel flow/heat input to the CT units, separately defining fuel flow/heat
input during the various system operating modes, including during
startups, warm-up periods, normal operation of the CT units, and during
shutdown.
c. To verify compliance with the operational limitations on the diesel-
driven fire pump, Permittee shall maintain a log reflecting hours of both
emergency and non-emergency operation. The log shall further include a
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
24 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
narrative explanation of the nature of any "emergency" that required
emergency use of the fire pump.
4. Parametric emissions monitoring - Volatile organic compounds
[Code §3-3-260.G.]
As a surrogate for monitoring actual emissions, Permittee shall periodically
calculate the quantity of VOC emissions on a basis adequate to comply with the
reporting requirements under this permit, by multiplying the aggregate fuel
flows/heat input by the corresponding VOC emission factors defined in an
approved performance test, or otherwise defined in this permit.
5. Parametric Emissions monitoring - Particulate matter
[Code §3-3-260.G.]
a. As a surrogate for monitoring actual PM10 emissions, Permittee shall
periodically calculate the quantity of PM10 emissions, by multiplying the
aggregate fuel flows/heat input by the corresponding PM10 emission
factors defined in an approved performance test, or otherwise defined in
this permit.
b. On at least a semi-annual basis during operations, Permittee shall
conduct a visual opacity screen performed on each stack. If visible
emission are observed, Permittee shall have a full Method 9 opacity test
performed by a certified opacity observer, and shall provide a copy of the
resulting report to the District within 10 days.
6. Parametric emissions monitoring - sulfur dioxide
[Code §3-3-260.G.]
As a surrogate measurement for monitoring emissions of sulfur dioxide,
Permittee shall maintain monthly records reflecting total fuel consumption in
each CT unit. On a cycle adequate to comply with the emission limitations and
quarterly reporting requirements under this permit, Permittee shall utilize the SO2
emission calculation methodology set forth in 40 CFR part 75, Appendix D §2.3,
to calculate and report SO2 emissions. Permittee shall determine fuel sulfur
content by either:
a. Maintaining a contractual commitment with the pipeline gas supplier
demonstrating that the gas has a hydrogen sulfide content of 1 grain/100
scf or less, and a total sulfur content of 20 grain/100 scf or less; or
b. At least annually, sampling and analyzing the composition of the
pipeline gas to show whether the gas has a hydrogen sulfide content of 1
grain/100 scf or less, and a total sulfur content of 20 grain/100 scf or less.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
25 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
7. Periodic monitoring - Emergency Fire Pump Fuel Sulfur Content.
As a surrogate measurement for quantifying the sulfur content in diesel fuel for
the emergency fire pump, Permittee shall maintain a contractual commitment
with or a certification from the Permittee's fuel supplier, showing that only diesel
fuel qualified for on-highway use is being delivered to the fire pump, which shall
constitute a demonstration of compliance with the 500 ppmw sulfur content
limitation defined above.
8. Parametric emission monitoring - Minimum Load Operation
[Code §3-3-260.G.]
Permittee shall maintain a 12 month rolling average showing the total power
produced for each individual turbine, and the number of operating hours for that
turbine unit. If permittee elects to also log startup and shutdown events,
permittee may correspondingly deduct cold start and shutdown times as defined
above for each such start/stop cycle for purposes of tabulating the annual
operating hours for that unit. The resulting product of the power produced for
each unit divided by the adjusted number of operating hours shall show that the
unit operated at least 32% of baseload capacity.
9. Parametric emission monitoring - General Maintenance
[Code §3-3-260.G.]
To assure compliance with the general maintenance obligation defined under this
permit, Permittee shall maintain repair logs with regard to each CT, and each
catalytic reactor unit.
10. Parametric emission monitoring - Operating Cycle
[Code §3-3-260.G.]
Permittee shall maintain a 12 month rolling average showing the total number of
operating hours, including startup and shutdown, for each individual turbine.
11. Parametric emission monitoring - Startup Events
[Code §3-3-260.G.]
Permittee shall maintain a 12 month rolling average showing the total number of
startup events for each individual turbine.
C. NESHAP Monitoring and Compliance for Emergency Compression Ignition Engines
[40 CFR §§63.6625(e), (f), (h), (i), 63.6640(f)]
1. Permittee shall maintain the engine according to the manufacturer’s emission-
related written instructions or develop your own maintenance plan which must
provide to the extent practicable for the maintenance and operation of the engine
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
26 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
in a manner consistent with good air pollution control practice for minimizing
emissions.
2. Permittee shall install a non-resettable hour meter if one is not already installed.
3. Permittee shall minimize the engine’s time spent at idle during startup and
minimize the engine’s startup time to a period needed for appropriate and safe
loading of the engine, not to exceed 30 minutes, after which time the non-startup
limitations of Tables 1a, 2a, 2c, and 2d to Subpart ZZZZ apply. of this permit
apply.
4. Permittee has the option of utilizing an oil analysis program in order to extend
the specified oil change requirements of this permit. The oil analysis shall be
performed at the same frequency specified for changing the oil in Section §5.C.2
of this permit. The analysis program shall at a minimum analyze the following 3
parameters: total Base Number, viscosity, and percent water content. The
condemning limits for these parameters are as follows: Total Base Number is less
than 30% of the Total Base Number of the oil when new; viscosity of the oil has
changed by more than 20% from the viscosity of the oil when new; or percent
water content (by volume) is greater than 0.5. If all these limits are not exceeded,
Permittee is not required to change the oil. If any of the limits are exceeded,
Permittee shall change the oil within 2 days of receiving the results of the
analysis, or if not in operation, within 2 days or before commencing operation,
whichever is later. Records of the parameters analyzed, results of the analysis
and oil changes shall be kept. The analysis program shall be part of the
maintenance plan for the engine.
5. Permittee shall not operate the emergency generator other than for emergency
operations, maintenance and testing, and operations in non-emergency situations
for up to 50 hours per year. These 50 hours cannot be used for peak shaving or
to generate income for a facility to supply power to a grid or otherwise supply
power as part of a financial arrangement with another entity, except for 15 hours
per years which may be used as part of a demand response program if the
regional transmission organization has determined there are emergency
conditions that could lead to a potential electrical blackout.
6. Operations during emergency situations is not limited.
7. Permittee may operate the emergency generator for the purpose of maintenance
checks and readiness testing, provided that the tests are recommended by
Federal, State or local government, the manufacturer, the vendor, or the
insurance company associated with the engine. Maintenance checks and
readiness testing is limited to 100 hours per year. The 50 hours of non-
emergency situations allowed in subsection 4 above count towards the 100 hours
for maintenance checks and readiness testing.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
27 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
D. Recordkeeping
[Mandated by 40 CFR §70.6(a)(3)] [40 CFR §§63.6655(a), (e)](Code §3-1-083)
1. Permittee shall maintain at the source, a file of all measurements, including
continuous monitoring-system-, monitoring-device-, and performance- testing
measurements; all continuous monitoring system performance evaluations; all
continuous monitoring system or monitoring device calibration checks;
adjustments and maintenance performed on these systems or devices; and all
other information required pursuant to any federally enforceable provision of this
permit, recorded in a permanent form suitable for inspection.
2. Permittee shall record the following in a permanent logbook, which may be in
written or digital form, for inclusion in the quarterly report:
a. Emissions of nitrogen oxides, carbon monoxide, particulate matter
(PM10), volatile organic compounds, and sulfur dioxide;
b. Total natural gas burned; and
c. CT run times.
d. The number of start-up and shut-down cycles for each CT unit.
e. For the generator, the records shall specify how many hours were spent
for emergency operations and non-emergency purposes, and if the
generator was used for demand response, the records shall include a
description of the emergency situation, and the time the engine was
operated as part of the demand response.
3. Permittee shall maintain records of the occurrence and duration of any start-up,
shutdown or malfunction in the operation of the permitted facility or any air
pollution control equipment.
4. Recordkeeping of Periodic Facility-Wide Activities (§3-1-081.A.3.b)
Each time an abrasive blasting or spray painting project is conducted, Permittee
shall record the following:
a. Date the project was conducted;
b. Duration of the project;
c. Type of control measures employed; and
d. Material Safety Data Sheets for all paints and solvents used in the
project.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
28 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
5. Permittee shall keep records of the maintenance conducted on the emergency
generators to demonstrate that they were operated and maintained according to
the maintenance plan or manufacture specification.
E. Compliance Reporting
[Mandated by 40 CFR §§70.6(a)(3) and 70.6(c)(4)] [40 CFR §§63.6640(b), 63.6650(a),
(c), (d)](Code §3-1-083.A)
1. In order to demonstrate compliance with the provisions of this permit, the
Permittee shall submit a quarterly report containing the information required to
be recorded pursuant to this permit. All instances of deviations from permit
requirements shall be clearly identified in such reports. For brevity, such
deviation reports may incorporate by reference any written supplemental upset
reports filed by Permittee during the reporting period. The report shall be
submitted to the District within 30 days after the end of each calendar quarter.
Appendix A of this permit is a form which may be used for the report.
2. With respect to emergency generators, if there are no deviations from any
emissions limitations or operating limitations that apply to the Permittee,
compliance reports after May 3, 2013 shall contain a statement that there were no
deviations from such limitations during the reporting period. If there was a
malfunction, the compliance report shall include the number, duration and brief
description for each malfunction which caused or may have caused any
applicable limitation to be exceeded, as well as a description of the actions taken
to minimize emissions during the malfunction and to correct the malfunction.
F. Regular Compliance/Compliance Progress Certification
[Mandated by 40 CFR §§70.5(c)(8), 70.5(c)(9), 70.6(c)(4), 70.6(c)(5)]
Permittee shall annually submit to the Control Officer, and also to the Administrator of
US EPA a certification of compliance with the provisions of this permit. The
certification shall be separately submitted to both the District and to the Enforcement
Office (AIR 5), EPA Region IX, 75 Hawthorne Street, San Francisco, CA 94105-3901.
The certification shall:
1. Be signed by a responsible official, as defined in 40 CFR 70.2, or such other
person as may be approved by the Control Officer as an administrative
amendment to this permit;
2. Identify each term or condition of the permit that is the basis of the certification;
3. Verify the compliance status with respect to each such term or condition;
4. Verify whether compliance with respect to each such term or condition has been
continuous or intermittent;
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
29 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
5. Identify the permit provision, or other, compliance mechanism upon which the
certification is based; and
6. Be postmarked within thirty (30) days of the start of each calendar year.
7. Other Reporting Obligations
A. Deviation Reporting Requirement
(Code §3-1-083.A.3.b.,§3-1-081.A.5) [Mandated by 40 CFR §§70.6(a)(3)(iii)(B),
70.6(g)]
Permittee shall report any deviation from the requirements of this permit along with the
probable cause for such deviation, and any corrective actions or preventative measures
taken to the District within fifteen days of when the owner or operator first learned of the
deviation unless earlier notification is required by the provisions of Section 9.P. of this
permit.
B. Annual emissions inventory
[Code §§3-1-103, 3-7-590.C.1.]
Permittee shall complete and submit to the District an annual emissions inventory,
disclosing actual emissions for the preceding calendar year. The submittal shall be made
on a form provided by the District. The inventory is due by the latter of March 31, or
ninety (90) days after the form is furnished by the District.
C. Greenhouse Gas Reporting
[40 CFR Part 98]
If this source becomes subject to the provisions of 40 CFR Part 98, then Permittee shall
comply with these provisions accordingly.
8. Fee Payment
[Mandated by 40 CFR §§70.6(a)(7), 70.9]
As an essential term of this permit, an annual permit fee shall be assessed by the District and paid
by Permittee in accord with the provisions of Code Chapter 3, Article 7 generally, and Code §3-1-
081.A.9. specifically. The annual permit fee shall be due on or before the anniversary date of the
issuance of an individual permit, or formal grant of approval to operate under a general permit.
The District will notify the Permittee of the amount to be due, as well as the specific date on
which the fee is due.
9. General Conditions
A. Term
[Mandated by 40 CFR §70.6(a)(2)] (Code §3-1-089)
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
30 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
This permit shall have a term of five (5) years, begining from the date of issuance.
B. Basic Obligation
[Mandated by 40 CFR §§70.4(b)(15), 70.6(a)(6(i), 70.6(a)(6)(ii), 70.7.b] (Code §3-1-
081.)
1. The owner or operator ("Permittee") of the facilities shall operate them in
compliance with all conditions of this permit, the Pinal County Air Quality
Control District ("the District") Code of Regulations ("Code"), and consistent
with all State and Federal laws, statutes, and codes relating to air quality that
apply to these facilities. Any permit noncompliance is grounds for enforcement
action; for a permit termination, revocation and reissuance, or revision; or for
denial of a permit renewal application and may additionally constitute a violation
of the Clean Air Act (1990).
2. All equipment, facilities, and systems used to achieve compliance with the terms
and conditions of this permit shall at all times be maintained and operated in
good working order.
C. Duty to Supplement Application
[Mandated by 40 CFR §§70.5(b), 70.6(a)(6)(v)] (Code §§3-1-050.H, 3-1-081.A.8.e, 3-1-
110)
Even after the issuance of this permit, a Permittee, who as an applicant who failed to
include all relevant facts, or who submitted incorrect information in an application, shall,
upon becoming award of such failure or incorrect submittal, promptly submit a
supplement to the application, correcting such failure or incorrect submittal. In addition,
Permittee shall furnish to the District within thirty days any information that the Control
Officer may request in writing to determine whether cause exists for modifying, revoking
and reissuing, or terminating this permit or to determine compliance with this permit
and/or the Code.
D. Right to Enter
[Mandated by 40 CFR §70.6(c)(2)] (Code § 3-1-132)
Authorized representatives of the District shall, upon presentation of proper credentials,
be allowed:
1. to enter upon the premises where the source is located or in which any records
are required to be kept under the terms and conditions of this permit;
2. to inspect any equipment, operation, or method required in this permit; and
3. to sample emissions from the source.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
31 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
E. Transfer of Ownership
[Mandated by 40 CFR §70.7(d)(4)]
This permit may be transferred from one person to another by notifying the District at
least 30 days in advance of the transfer. The notice shall contain all the information and
items required by Code § 3-1-090. The transfer may take place if not denied by the
District within 10 days of the receipt of the transfer notification.
F. Posting of Permit
(Code §3-1-100)
Permittee shall firmly affix the permit, an approved facsimile of the permit, or other
approved identification bearing the permit number, upon such building, structure, facility
or installation for which the permit was issued. In the event that such building, structure,
facility or installation is so constructed or operated that the permit cannot be so placed,
the permit shall be mounted so as to be clearly visible in an accessible place within a
reasonable distance of the equipment or maintained readily available at all times on the
operating premises.
G. Permit Revocation for Cause
[Mandated by 40 CFR §70.6(a)(6)(iii)] (Code §3-1-140)
The Director of the District ("Director") may issue a notice of intent to revoke this permit
for cause pursuant to Code §3-1-140, which cause shall include occurrence of any of the
following:
1. The Director has reasonable cause to believe that the permit was obtained by
fraud or material misrepresentation;
2. Permittee failed to disclose a material fact required by the permit application
form or a regulation applicable to the permit;
3. The terms and conditions of the permit have been or are being violated.
H. Certification of Truth, Accuracy, and Completeness
[Mandated by 40 CFR §§70.5(a)(2), 70.6(a)(3)(iii)(B)] [Federally enforceable - Code
§§3-1-083.A.5, 3-1-175 (as amended 2/22/95) approved as SIP Elements at 65 FR
79742 (12/20/00)]
Any application form, report, or compliance certification submitted pursuant to the Code
shall contain certification by a responsible official of truth, accuracy, and completeness.
This certification and any other certification required under Chapter 3 of the Code shall
state that, based on information and belief formed after reasonable inquire, the statements
and information in the document are true, accurate, and complete.
I. Expiration and Renewal of Permit
[Mandated by 40 CFR §§70.5(a)(1)(iii), 70.7(c)](Code §3-1-050.C)
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
32 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
Expiration of this permit will terminate the facility’s right to operate unless either a
timely application for renewal has been submitted in accordance with §§3-1-050, 3-1-055
and 3-1-060, or a substitute application for a general permit under §3-5-490. For Class I
permit renewals, a timely application is one that is submitted at least 6 months, but not
greater than 18 months prior to the date of the permit expiration. For Class II or Class III
permit renewals, a timely application is one that is submitted at least 3 months, but not
greater than 12 months prior to the date of permit expiration.
J. Severability
[Mandated by 40 CFR §70.6(a)(5)]
Pursuant to Code § 3-1-081.A.7., the provisions of this permit are severable, and if any
provision of this permit is held invalid the remainder of this permit shall not be affected
thereby.
K. Permit Shield
[Mandated by 40 CFR §70.6(f)] (Code § 3-1-102.)
Subject to the following schedule of exclusions, compliance with the terms of this permit
shall be deemed compliance with any applicable requirement identified in this permit.
The permit-shield exclusions include:
1. PGCAQCD Rule §7-2-1.8 ANTI-DEGRADATION;
2. Items listed in Section 10 of this permit as not being federally enforceable.
L. Permit Revisions
[Mandated by 40 CFR §70.7(d), 70.7(e)] (Code Chapter 3, Article 2)
1. This permit may be revised, reopened, revoked and reissued, or terminated for
cause. The filing of a request by the permittee for a permit revision, revocation
and reissuance, or termination, or of a notification of planned changes or
anticipated noncompliance does not stay any permit condition.
2. The permittee shall furnish to the Control Officer, within a reasonable time, any
information that the Control officer may request in writing to determine whether
cause exists for revising, revoking and reissuing, or terminating the permit or to
determine compliance with the permit.
3. Permit amendments, permit revisions, and changes made without a permit
revision shall conform to the requirements in Article 2, Chapter 3, of the Code.
4. Revision to Obtain Authority to Reconstruct [Federally enforceable - 40 CFR
63.42(c)] Code §3-1-040.D.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
33 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
Prior to commencing a reconstruction, as defined below, Permittee shall apply
for and obtain a revision to this permit, which revised permit shall include a final
and effective case-by-case determination pursuant to the provisions of 40 CFR
63.43 such that the emissions from the reconstructed facility will be controlled to
a level no less stringent than the maximum achievable control technology
emission limitation for new sources.
For purposes of this subsection, "reconstruction" is defined as the replacement of
components at an existing process or production unit that in and of itself emits or
has that potential to emit 10 tons per year of any HAP or 25 tons per year of any
combination of HAP, whenever:
a. The fixed capital cost of the new components exceeds 50 percent of the
fixed capital cost that would be required to construct a comparable
process or production unit; and
b. It is technically and economically feasible for the reconstructed major
source to meet the applicable maximum achievable control technology
emission limitation for new sources established under 40 CFR Part 63,
Subpart B.
M. Permit Re-opening
[Mandated by 40 CFR §§70.6(a)(6)(iii), 70.7(g), ] (Code §§ 3-1-050.C.6, 3-1-087.)
1. This permit shall be reopened if:
a. Additional applicable requirements under the Clean Air Act (1990)
become applicable to this source, and on that date, this permit has a
remaining term of three or more years. Provided, that no such reopening
under this subparagraph is required if the effective date of the newly
applicable requirement is later than the date on which this permit is due
to expire, unless the original permit or any of its terms and conditions has
been extended pursuant to Code §3-1-089.C.
b. If the Permittee becomes subject to a standard promulgated by the
Administrator under Section 112(d) of the CAA, the Permittee shall,
within 12 months of the date on which the standard was promulgated,
submit an application for a permit revision demonstrating how the source
will comply with the standard.
b. The Control Officer determines that it contains a material mistake or that
inaccurate statements were made in establishing the emissions standards
or other terms or conditions of it;
c. The Control Officer determines that it needs to be revised or revoked to
assure compliance with the applicable requirements; or
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
34 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
d. The EPA Administrator finds that cause exists to terminate, modify, or
revoke and reissue this permit.
2. If this permit must be reopened or revised, the District will notify the permittee in
accord with Code §3-1-087.A.3.
N. Record Retention
[Mandated by 40 CFR §70.6(a)(3)(ii)(B)] (Code §3-1-083.A.2.b)
Permittee shall retain for a period of five (5) years all documents required under this
permit, including reports, monitoring data, support information, calibration and
maintenance records, and all original recordings or physical records of required
continuous monitoring instrumentation.
O. Scope of License Conferred
[Mandated by 40 CFR §70.6(a)(6)(iv)] (Code §3-1-081.)
This permit does not convey any property rights of any sort, or any exclusive privilege.
P. Excess Emission Reports; Emergency Provision
[Mandated by 40 CFR §70.6(g)] (Code §3-1-081.E, Code §8-1-030)
1. To the extent Permittee may wish to offer a showing in mitigation of any
potential penalty, underlying upset events resulting in excess emissions shall
reported as follows:
a. The permittee shall report to the Control Officer any emissions in excess
of the limits established by this permit. Such report shall be in two parts:
i. Notifications by telephone or facsimile within 24 hours or the
next business day, whichever is later, of the time when the owner
or operator first learned of the occurrence of excess emissions,
including all available information required under subparagraph
b. below.
ii. Detailed written notification within 3 working days of the initial
occurrence containing the information required under
subparagraph b. below.
b. The excess emissions report shall contain the following information:
i. The identity of each stack or other emission point where the
excess emissions occurred.
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
35 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
ii. The magnitude of the excess emissions expressed in the units of
the applicable limitation.
iii. The time and duration or expected duration of the excess
emissions.
iv. The identity of the equipment from which the excess emissions
occurred.
v. The nature and cause of such emissions.
vi. If the excess emissions were the result of a malfunction, steps
taken to remedy the malfunction and the steps taken or planned
to prevent the recurrence of such malfunctions.
vii. The steps that were or are being taken to limit the excess
emissions. To the extent this permit defines procedures
governing operations during periods of start-up or malfunction,
the report shall contain a list of steps taken to comply with this
permit.
viii. To the extent excess emissions are continuous or recurring, the
initial notification shall include an estimate of the time the
excess emissions will continue. Continued excess emissions
beyond the estimated date will require an additional notification.
2. An "emergency" means any situation arising from sudden and reasonably
unforeseeable events beyond the control of the source, including acts of God,
which situation requires immediate corrective action to restore normal operation,
and that causes the source to exceed a technology-based emission limitation
under the permit, due to unavoidable increases in emissions attributable to the
emergency. An emergency shall not include noncompliance to the extent caused
by improperly designed equipment, lack of preventative maintenance, careless or
improper operation, or operator error.
3. An emergency constitutes an affirmative defense to an action brought for
noncompliance with such technology-based emission limitations if the conditions
of the following subparagraph are met.
4. The affirmative defense of emergency shall be demonstrated through properly
signed, contemporaneous operating logs, or other relevant evidence that:
a. An emergency occurred and that the permittee can identify the cause(s)
of the emergency;
b. The permitted facility was at the time being properly operated;
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
36 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
c. During the period of emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emissions standards or
other requirements in the permit; and
d. The permittee submitted notice of the emergency to the Control Officer
by certified mail or hand delivery within 2 working days of the time
when emissions limitations were exceeded due to emergency. The notice
shall contain a description of the emergency, any steps taken to mitigate
emissions, and corrective action taken.
10. Additional provisions applicable to Title V Sources
A. Enforcement by the Administrator and Citizens
[Mandated by 40 CFR §70.6(b)]
All terms and conditions in this permit not excluded in Section 10.B. are enforceable by
the Administrator and citizens under the Clean Air Act.
B. Federal Enforceability Exclusions
[Mandated by 40 CFR §70.6(b)(2)]
To the extent that they are enforceable at all, the following terms and conditions are
enforceable only under authority of State law:
Section 1. - Introduction - This merely constitutes factual background regarding the
facility.
Section 5.D.2 - Fuel Burning Equipment; the cited local rule has not been approved as a
SIP element.
Section 5.F.3 - Opacity; the cited local rule has not been approved as a SIP element.
Section 9.F - Posting of Permit; the cited local rule has not been approved as a SIP
element.
11. Equipment
[Mandated by 40 CFR §70.5(c)(3)(ii)] (Code §3-1-050.B)
Equipment for which emissions are allowed by this permit are as follows:
1. 10 Combustion turbines, General Electric LM6000 SPRINT, natural gas fired, 446
mmbtu/hr each - high heating value, equipped with CEMs, oxidation catalyst and
selective catalytic reduction (SCR).
2. Clean-O-Matic Solvent tank, 85 gal
3. Clarke Fire water pump powered by a John Deere, 183 horsepower, diesel fired engine,
manufactured in October 2001
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
37 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
12. Insignificant Activities
[Mandated by 40 CFR §70.5(c) (Code §3-1-050.E)
Permittee has disclosed the following insignificant activities in the application for this permit:
Emission Point Possible Discharge
Acetylene, Butane, Propane Torches/Cylinders Acetylene, Butane, Propane
Activities Associated with Maintenance Repair or Dismantlement
of an Emission Unit or Other Equipment.
VOC
Aerosol Can Usage VOCs
Ammonia Storage Ammonia Vapor
Barrels/Totes/Bins (Oil Storage Building) - Miscellaneous
Lubricating Oil Storage
Oil Vapors
Brazing and Soldering Activities PM10, Fumes
Cathodic Protection Ozone
Caustic Tank Caustic Vapors
Circuit Breakers Ozone, Oil Vapor
Combustion Turbine Chemicals Chemical Vapors
Combustion Turbine Gas Vents Natural Gas
Combustion Turbine – Lube Oil Vents Oil Vapor
Combustion Turbine – False Start Drains Oil Vapor
Corona Ozone
Electric Motors Ozone
Fuel Oil Storage VOCs
Gas Yard Vents Natural gas
Hydraulic Systems Reservoirs Oil Vapor
Lube Oil Storage Area Oil Vapor
Normal Use of Consumer Products (e.g. cleaning, janitorial,
medical, etc)
CFCs, VOC
Oil Filter Draining Oil Vapor
Pesticide/Herbicide Activity Pesticide, Herbicide
Pump/Motor Oil Reservoirs Oil Vapor
Piping System, Fuel VOCs
Safety Devices, Fire Extinguishers and Cardox System PM10
Septic Tanks – Guard Shack & Admin Building Methane
Battery Banks Acid Vapor
Transformers Oil Vapor
Welding Activities Welding Fumes
Food Processing Equipment PM
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
38 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
Tobacco Smoking Areas PM
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
39 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
Appendix A
Quarterly Report
Permit #V20667.000
Abstract
This constitutes a quarterly report of all required monitoring, documenting emissions during the subject
reporting period.
Reporting Period - Quarter 1st 2nd 3rd 4th Year _________
Facility - Sundance Power Plant
2060 W Sundance Rd
Casa Grande, AZ
Parametric emissions report
Natural gas burned during reporting period mmBtu
Operations report
Power generated during reporting period megawatt-hours
CT Unit #1
"normal" run time hours
Start-up cycles each
CT Unit #2
"normal" run time hours
Start-up cycles each
CT Unit #3
"normal" run time hours
Start-up cycles each
CT Unit #4
"normal" run time hours
Start-up cycles each
CT Unit #5
"normal" run time hours
Start-up cycles each
CT Unit #6
"normal" run time hours
Start-up cycles each
CT Unit #7
"normal" run time hours
Start-up cycles each
CT Unit #8
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
40 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
"normal" run time hours
Start-up cycles each
CT Unit #9
"normal" run time hours
Start-up cycles each
CT Unit #10
"normal" run time hours
Start-up cycles each
Emergency Generator run time (starting May 3, 2013) ............. ______________ emergency hours
__________non-emergency Hours
Was the emergency generator operated and maintained in accordance with the operational
limitations of §5.C.2? ......................................................................................................... YES / NO
Pursuant to §5.H were records of surface stabilization control measures implemented on open
areas/vacant lots and unpaved lots maintained? ............................................................... YES / NO
If required, describe and explain any monitoring activity or recordkeeping that occurred with
respect to the Asbestos NESHAP or Stratospheric Ozone requirements respectively defined in
§§5.K.1 and 5.K.2 of the permit during the reporting period. Is such a supplemental disclosure
attached? ............................................................................................................................ YES / NO
Pursuant to the NOx emission limitation of ¶4.B.2.a.1, did the monitoring records under ¶6.B.1
show continuous compliance during the quarter? .............................................................. YES / NO
Pursuant to the CO emission limitations of ¶4.B.2.a.2, did the monitoring records under ¶6.B.2
show continuous compliance during the quarter? .............................................................. YES / NO
Pursuant to ¶6.B.3.c, were records of the non-emergency operation of the diesel-driven fire pump
maintained during the quarter? .......................................................................................... YES / NO
Have opacity screens been performed pursuant to ¶6.B.5? ............................................... YES / NO
Pursuant to ¶6.B.6, has natural gas sulfur content been monitored by:
○ maintaining a contractual commitment to purchase only conforming pipeline natural
gas?........................................................................................................................YES / NO
○ testing and analyzing gas on at least an annual basis? ......................................... YES / NO
Pursuant to ¶6.B.7, has diesel fuel sulfur content been monitored by maintaining a contractual
commitment to purchase only on-road diesel fuel? ........................................................... YES / NO
Pursuant to ¶6.B.8, have monthly rolling averages of power production, calculated as a function
of baseload, been maintained? .......................................................................................... YES / NO
S:\Word\PERMITS\Issued.v\V20667.ISS.docx V20667.000
41 (6/30/16) ARIZONA PUBLIC SERVICE – CASA GRANDE
○ Do those averages show compliance with ¶4.B.2.d? ............................................ YES / NO
Have repair logs been maintained pursuant to ¶6.B.9? ...................................................... YES / NO
Pursuant to ¶6.B.10, have monthly rolling averages of operating hours been maintained?
........................................................................................................................................... YES / NO
○ Do those averages show compliance with ¶4.A.2? ............................................... YES / NO
Pursuant to ¶6.B.11, have monthly rolling averages of startup operations been maintained? .YES /
NO
○ Do those averages show compliance with ¶4.A.3? ............................................... YES / NO
Pursuant to §6.E, on a separate sheet, describe and explain any previously un-reported deviations
from the terms of this permit. Is such a supplemental disclosure attached? ..................... YES / NO
Emissions report
Emissions of nitrogen oxides tons
Emissions of carbon monoxide tons
Emissions of particulate matter (PM10) tons
Emissions of volatile organic compounds tons
Emissions of sulfur dioxide tons
Certification by Responsible Official
I certify that, based on information and belief formed after reasonable inquiry, that the statements and
information in this report are true, accurate and complete.
Signed _______________________________________________
Printed Name __________________________________________
Title _________________________________________________
Date ________________ Contact Phone Number ___________
Mail to - Pinal County Air Quality Control District
PO Box 987
Florence, AZ 85132